Conflict of Interest


USF Policies 0-309 and 0-317 which govern research related conflicts of interest were revised in April of 2017 to change part of the definition of Significant Financial Interest. The revised policies consider a propriety interest to be present as soon as a patent is granted or an option or license agreement is executed (including option and license agreements for provisional patents, patent applications, etc.). The previous definition considered a proprietary interest to be present as soon as protection was sought. The definition of a proprietary interest still includes copyrights, trademarks and royalties.

Please contact the COI Program ( with any questions regarding the revisions or other types of Significant Financial Interests (e.g consulting income, speaking fees, equity interest, position on a board of directors, etc.). The revised policies are available via the COI Program website (Policies and Procedures) and the USF Office of the General Counsel website.

PHS Objectivity Rule on Financial Conflicts of Interest in Research (PDF)

NIH Final Rule on Objectivity in Research is Out! (PDF)

The USF Policy (0-309) regarding individual conflicts of interest has been revised and contains several important changes that will affect faculty and staff.

  1. Effective January 29, 2015, all federally-funded Investigators must complete an Interest Inventory prior to proposal submission via the eCOI module in ARC.
  2. Effective January 29, 2015, subrecipients on National Science Foundation-funded projects, as well as those on projects funded by the U.S. Public Health Service and agencies or extramural sponsors who have adopted the PHS regulation regarding objectivity in research, must certify at proposal that they have an NSF- or PHS-compliant COI policy (whichever is appropriate based on the prime source of funding), OR must agree to follow USF's COI Policy and submit COI disclosure forms prior to submission. See the COI Program website, Policies and Procedures page for additional information about this process and for a link to the database in which subrecipients must complete and submit their disclosures.
  3. The University's threshold for disclosure of a Significant Financial Interest has changed. Significant Financial Interest is now defined as follows:
  4. An opportunity for the Investigator (or his/her Immediate Family) for economic gain or an external commitment that relates to, or could reasonably be affected by, the outcome of the proposed or current USF Research Project, including:
    • the value of any remuneration and equity interest in a publicly-traded entity that exceeds $5,000 over the previous 12 months;
    • remuneration received from a non-publicly traded entity that exceeds $5,000 over the previous 12 months;
    • any equity in a non-publicly traded entity;
    • a position as director, officer, partner, trustee or member of board of directors of any entity related to the USF Research Project, whether or not compensation is received for such service;
    • a proprietary interest in the USF Research Project;
    • for PHS-funded Investigators only, reimbursed or sponsored travel; and
    • any other financial interest or external commitment that an Investigator believes may interfere with his or her ability to oversee or participate in research without bias.